GV.RR-01: Organizational leadership is responsible and accountable for cybersecurity risk and fosters a culture that is risk-aware, ethical, and continually improving

To meet the gv.rr-01: organizational leadership is responsible and accountable for cybersecurity risk and fosters a culture that is risk-aware, ethical, and continually improving requirement, you must assign explicit leadership accountability for cyber risk, formalize governance routines (reporting, decisions, funding), and prove culture is actively managed through measurable behaviors and continuous improvement. Your fastest path is to map GV.RR-01 to policies, owners, and recurring evidence tied to board/executive oversight. ¹

Key takeaways:

• Assign named executive/board-level accountability for cybersecurity risk, with decision rights and reporting cadence documented. ¹
• Operationalize “culture” with measurable expectations: training, speak-up mechanisms, risk acceptance workflow, and consequences. ¹
• Build an evidence system: charters, minutes, risk reports, decisions, and improvement actions mapped directly to GV.RR-01. ²

GV.RR-01 sits in the governance layer of NIST CSF 2.0 and is easy to “say” and hard to prove. Auditors, customers, and regulators rarely accept a claim like “leadership supports security” without artifacts that show who is accountable, what decisions they make, how often they review risk, and how the organization learns from failures. GV.RR-01 requires two outcomes: (1) leadership accountability for cybersecurity risk and (2) a risk-aware, ethical, continually improving culture. ¹

For a Compliance Officer, CCO, or GRC lead, this requirement is operationalized by turning governance into a repeatable control: defined roles, formal forums, standardized reporting, documented risk decisions, and a closed-loop improvement mechanism. The practical challenge is scope: “organizational leadership” includes the board (or equivalent governing body), executive management, and the leaders who own major risk domains (technology, product, operations, legal, finance). Culture also spans HR, training, incentives, and internal communications, not just security tooling.

This page gives requirement-level implementation guidance you can deploy quickly: who it applies to, what to build, what evidence to keep, and what typically fails under audit. ¹

Regulatory text

Excerpt (GV.RR-01): “Organizational leadership is responsible and accountable for cybersecurity risk and fosters a culture that is risk-aware, ethical, and continually improving.” ¹

Operator interpretation (what you must do):

1. Make accountability explicit. “Leadership is responsible” must be expressed as named roles with defined duties, authority, and escalation paths for cybersecurity risk. ¹
2. Prove active governance. Leadership must receive cybersecurity risk information, make decisions (priorities, exceptions, funding), and track outcomes. ¹
3. Run culture as a managed program. “Risk-aware and ethical” means staff know expected behaviors, can raise concerns safely, and leadership reinforces expectations through training, communications, and consequences. “Continually improving” means you track gaps and corrective actions through to closure and feed lessons back into controls. ¹

Plain-English interpretation of the requirement

GV.RR-01 means cybersecurity risk is not “owned by the CISO.” Senior leadership owns it, makes trade-offs, and can show their work. You need a governance structure where cyber risk is discussed like financial risk: regularly, using consistent reporting, with documented decisions and follow-through. ¹

“Culture” here is not a poster campaign. It is the set of expectations and behaviors you can measure: completion of training, participation in incident exercises, timely risk escalations, responsible use of access, and adherence to ethical standards when handling data and customer trust. Leadership must set the tone and put enforcement behind it. ¹

Who it applies to

Entity scope: Any organization operating a cybersecurity program, regardless of industry, because governance and leadership accountability are framework-level expectations. ¹

Operational scope (where it shows up in practice):

• Board/executive oversight of cyber risk and material risk decisions (risk acceptance, major exceptions, investment prioritization).
• Enterprise risk management and compliance reporting (risk registers, key risk indicators, executive dashboards).
• HR and people programs that shape behavior (training, onboarding, performance expectations, disciplinary pathways).
• Third party relationships where leadership approves risk posture (critical third party approvals, outsourcing strategy, concentration risk decisions).

What you actually need to do (step-by-step)

The fastest operationalization is to treat GV.RR-01 as a governance control with a clear owner, a set of required meetings and reports, and recurring evidence capture. A recommended control approach is to map GV.RR-01 to policy, procedure, control owner, and recurring evidence collection. ^{1 2}

Step 1: Assign leadership accountability and decision rights

• Name the accountable executive for cybersecurity risk (commonly CISO with CRO/CTO shared accountability, or another executive depending on structure) and document it in a governance charter or policy.
• Define decision rights for:
  • risk acceptance thresholds and who can approve exceptions,
  • prioritization of remediation and security initiatives,
  • incident escalation authority and external notifications coordination.
• Define board (or equivalent) oversight: which committee receives cyber reporting and what they must review. ¹

Deliverable: Cybersecurity governance charter + RACI (Responsible/Accountable/Consulted/Informed) for cyber risk decisions.

Step 2: Create a leadership operating cadence (the “forum + packet + minutes” model)

Stand up at least one formal governance forum where cyber risk is reviewed and decisions are recorded. Keep it simple and repeatable:

• Forum: “Cyber Risk Steering Committee” (or fold into an existing enterprise risk committee).
• Packet: standardized reporting that leadership can compare over time (top risks, trend, incidents, third party risk hotspots, open audit findings, remediation status, exceptions requiring approval).
• Minutes: decisions, action items, owners, due dates, and risk acceptances. ¹

Practical tip: If you cannot produce meeting minutes and decision logs, auditors will treat leadership accountability as aspirational.

Step 3: Build a documented risk acceptance and exception workflow

Culture and accountability become real when leadership signs risk:

• Define what counts as a cyber risk exception (example: unpatched critical system, incomplete logging, missing MFA for a legacy app).
• Require a written risk statement: system scope, threat scenario, compensating controls, residual risk, expiration date, and approver.
• Centralize approvals in a risk acceptance register with expirations and renewal workflow. ¹

Step 4: Operationalize “risk-aware and ethical culture” with specific mechanisms

You need a small set of mechanisms that translate culture into observable behavior:

• Mandatory training and attestation (security awareness, acceptable use, data handling). Tie role-based training to privileged access.
• Speak-up and escalation channels: an internal reporting path for security concerns and ethical issues, with non-retaliation expectations reinforced by leadership communications.
• Phishing simulation or equivalent behavior testing if your program uses it, plus coaching and follow-up.
• Leadership communications: periodic messages that set expectations (for example: no credential sharing, report suspicious activity, follow secure change practices). ¹

Keep this “culture set” auditable: who received training, who completed it, what communications were sent, and what happened when someone raised a concern.

Step 5: Prove “continually improving” through a closed-loop system

Continuous improvement must show inputs, actions, and outcomes:

• Inputs: incidents, near misses, audit findings, risk assessments, third party issues.
• Actions: corrective action plans with owners and target dates.
• Outcomes: closure evidence and control updates (policy changes, new monitoring, redesigned process). ¹

If you already run an issue management program (GRC platform, ticketing system), connect it to leadership reporting: aging, overdue items, recurring root causes.

Step 6: Map GV.RR-01 to controls and recurring evidence collection

Do the mapping explicitly so you can answer “show me” requests quickly:

• Policy mapping (governance policy, risk management policy, code of conduct references where relevant).
• Procedure mapping (committee cadence, risk acceptance procedure, escalation procedure).
• Control owner mapping (named accountable leader and operational owners).
• Evidence mapping (what you collect each month/quarter and where it is stored). ²

If you use Daydream, treat this as a living requirement page: link the charter, RACI, meeting minutes, risk acceptance log, and culture artifacts to GV.RR-01 so audits become a retrieval exercise rather than a scramble.

Required evidence and artifacts to retain

Use this as your audit readiness checklist:

Evidence	What it proves	Owner
Cybersecurity governance charter (board/executive)	Leadership accountability, scope, decision rights	CISO/CCO
RACI for cybersecurity risk	Clear responsibility and accountability	GRC
Committee calendar + agendas	Governance cadence exists	GRC/Exec Admin
Meeting minutes + decision log	Leadership makes and records decisions	Committee Chair
Cyber risk reporting packet (samples over time)	Leadership receives risk information	CISO/GRC
Risk acceptance register + approvals	Accountability for exceptions and residual risk	GRC/Risk
Training completion reports + role-based training matrix	Risk-aware culture is operational	HR/Security
Incident postmortems + corrective action tracking	Continuous improvement loop	Security/IT
Internal communications from leadership	Tone and ethical expectations	Comms/HR

Common exam/audit questions and hangups

Auditors usually probe three gaps: accountability, evidence of decisions, and culture proof.

Typical questions:

• “Who is accountable for cybersecurity risk at the executive level? Show me where that is documented.”
• “Show the last two leadership reviews of cyber risk and the actions taken.”
• “How do you approve and track risk acceptances and exceptions?”
• “How do you measure security culture beyond training completion?”
• “How do lessons learned change controls?” ¹

Hangups:

• Meeting minutes exist but contain no decisions, only presentations.
• Risk reports are highly technical and do not show business impact or prioritization.
• Exceptions are approved in email/Slack with no register, no expiry, and no review loop.

Frequent implementation mistakes and how to avoid them

1. Naming accountability without authority. If the accountable leader cannot prioritize remediation or force decisions, the role is symbolic. Fix it by defining decision rights and escalation paths in the charter. ¹
2. Treating culture as annual training only. Training completion is necessary but thin. Add speak-up mechanisms, leadership communications, and measurable follow-up for repeated failures. ¹
3. No “risk acceptance hygiene.” Untracked exceptions quietly become permanent. Require expirations, periodic review, and leadership visibility into overdue items. ¹
4. Evidence scattered across inboxes. Centralize artifacts by requirement. A GV.RR-01 evidence folder (or a Daydream control/evidence workspace) prevents last-minute evidence hunts. ²

Enforcement context and risk implications

NIST CSF is a framework, not a penalty schedule in the provided sources. Your practical risk is indirect: customers, sector regulators, and auditors often interpret weak leadership accountability as a root cause of control failures. If leadership cannot show governance and decisioning, you will struggle to defend risk acceptances after incidents and may face contractual, examination, or assurance consequences.

A practical 30/60/90-day execution plan

Use this as an execution checklist; adjust sequencing to your governance calendar.

First 30 days (establish accountability and minimum governance)

• Draft or refresh the cybersecurity governance charter (accountable leader, board oversight path, committee scope). ¹
• Publish a cyber risk RACI and confirm it with executives.
• Stand up a standardized cyber risk reporting template and agree on the standing agenda.
• Create a single evidence repository mapped to GV.RR-01 (charter, RACI, minutes, risk reporting). ²

Next 60 days (make decisions traceable; make culture auditable)

• Launch the risk acceptance/exception procedure with a register, required fields, and approval routing.
• Run at least one leadership cyber risk review meeting with recorded decisions and action items.
• Define culture measures you can evidence now: training completion, escalation channel usage, policy attestations, repeat failure handling. ¹

By 90 days (close the loop and institutionalize)

• Add corrective action tracking tied to incidents, audits, and risk assessments; report aging items to leadership.
• Conduct a leadership tabletop exercise or incident review to test escalation and decisioning, then document improvements.
• Operationalize recurring evidence collection (monthly/quarterly) so GV.RR-01 stays continuously audit-ready. ²

Frequently Asked Questions

Does GV.RR-01 require board involvement?

It requires “organizational leadership” accountability and a culture fostered from the top. In many organizations that means board or governing-body oversight, even if day-to-day accountability sits with an executive. ¹

What is the minimum evidence that convinces an auditor this is real?

A signed governance charter, a defined RACI, and recurring leadership meeting minutes that show actual decisions (risk acceptance, prioritization, resourcing) cover the core. Add a risk acceptance register and corrective action tracking to demonstrate continuous improvement. ¹

How do we prove “culture” without running employee surveys?

Use operational signals you can document: training/attestation completion, policy exception trends, escalation channel records, and documented coaching or disciplinary follow-up for repeated unsafe behavior. Keep it tied to defined expectations. ¹

Our executives hate technical metrics. What should we report?

Report risk in business terms: top enterprise cyber risks, material third party concentrations, open high-severity issues, exception count and age, and progress against agreed remediation priorities. Keep the technical detail in an appendix. ¹

Can the CISO be accountable if IT owns remediation?

Yes, if decision rights and escalation are defined and leadership governance forces resolution when remediation stalls. Document who decides, who funds, and how disputes get resolved. ¹

How do we keep GV.RR-01 from becoming a once-a-year documentation exercise?

Make evidence collection part of the operating cadence: every leadership meeting produces minutes and a decision log, every exception has an expiration and review, and every incident generates corrective actions tracked to closure. Map each artifact directly to GV.RR-01 in your GRC system or Daydream. ²

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes